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Micheal Oluwole (‘the Plaintiff’) commenced the action on 8 March 2024 by a Writ of Summons and Statement of Claim against Mrs. Osinachi Joseph Egbu, popularly known as Sinach (‘the Defendant’), in respect of the musical work titled Way Maker.

The dispute arose from the Plaintiff’s involvement in the recording and production of Way Maker. In the course of the engagement, the Plaintiff worked as a studio engineer and provided recording, mixing and mastering services. He also worked on the melodies and parts of several musical instruments used as accompaniments to the Defendant’s vocals in the recorded version of the song.

Before the Plaintiff’s involvement, the Defendant had written and composed Way Maker and had performed it in South Africa. She later engaged the Plaintiff to work on the existing song and to provide sound production, mixing and mastering services in connection with its development and recording. The parties did not execute a written agreement setting out the terms of the engagement or their respective interests in the work. The engagement was based on an oral arrangement, and payments made to the Plaintiff through Slic Inspire Limited included ?192,000 on 20 October 2015 and ?448,000 on 10 December 2015.

A disagreement subsequently arose over the nature and extent of the Plaintiff’s contribution to, and rights in, the musical work. The Plaintiff consequently instituted the present action, seeking, amongst other reliefs, declarations that he was an author and co-owner of Way Maker; an equitable division of income derived from the work; disclosure and accounts of licences and assignments relating to the work; ?5 billion in general damages; and an injunction restraining further exploitation of the work.

One of the issues for determination was: Whether this Honourable Court can make a determination on whether the Plaintiff is the author, writer, composer, creator, co-owner and performer of the musical instruments in the musical work/song, ‘Way Maker’.

ARGUMENTS

Learned counsel for the Plaintiff submitted that the Plaintiff’s contribution to Way Maker was creative and not merely technical. Counsel argued that the Plaintiff composed the melodies and instrumental parts accompanying the Defendant’s vocals and thereby contributed original expression to the musical work. It was submitted that the persons who created a musical work are its authors and copyright owners and that, where different persons have interests in the various copyrights comprising a composite production, they are deemed co-owners. Counsel therefore contended that Way Maker, being a composite production comprising the respective contributions of the Plaintiff and the Defendant, gave rise to joint authorship and co-ownership.

Learned counsel further submitted that the Plaintiff’s engagement went beyond technical mixing and mastering services because he contributed original musical elements to the finished work. Counsel maintained that the Defendant’s vocals and the Plaintiff’s melodies and instrumental accompaniments were distinct but inseparable elements of the musical work and that each party therefore held an interest in the copyright arising from his or her contribution.

Counsel also argued that payment for the Plaintiff’s services did not, without more, extinguish or transfer the copyright in his creative contribution. There was no written agreement assigning his interest to the Defendant, limiting his role to that of a mixing and mastering engineer, or providing that the payments constituted full and final settlement of his proprietary rights. Counsel therefore maintained that the Plaintiff retained copyright in his contribution and was entitled to recognition as a co-author and co-owner, together with a corresponding share of the royalties and income derived from the exploitation of Way Maker.

In response, learned Senior Counsel for the Defendant submitted that the Plaintiff failed to establish that he was an author or co-owner of Way Maker. Counsel argued that the Defendant had written, composed, arranged and performed the song before engaging the Plaintiff, including at an earlier performance in South Africa. The Plaintiff was subsequently retained to provide sound production, mixing and mastering services and to assist in developing the existing song into an album. Such involvement, counsel submitted, did not confer authorship or co-ownership of the underlying musical work.

Learned Senior Counsel further relied on the Plaintiff’s admission that the parties had agreed on remuneration for his services and that he had been paid. He argued that the payments of ?192,000.00 and ?448,000.00 were consistent with an engagement for services and not with any agreement for co-ownership. He also submitted that, because the Plaintiff sought declaratory reliefs, he had to establish authorship on the strength of his own evidence. His failure to place Way Maker before the Court meant that the Court could not identify or assess the original musical elements allegedly created by him. Counsel therefore urged the Court to hold that the Plaintiff had not proved authorship or co-ownership of the work.

DECISION OF THE COURT

In resolving the issue, the Federal High Court held that:

Not every person involved in the creation of a recording is necessarily an author. A producer, engineer, session musician or sound technician may contribute materially to the finished product without becoming an author unless they create original expressive content. Authorship resides in the original creative mind responsible for the intellectual creation.

The Federal High Court explained that an author is the natural person who creates the intellectual property embodied in a musical work, including its melody, harmony, lyrics or arrangement. Copyright vests in the author from the moment of creation, without the need for registration or formal notice, and confers exclusive rights to reproduce, distribute, perform and license the work. A musician who, as a composer, creates an original work through his ingenuity acquires an intellectual interest in that work which ranks pari passu with other proprietary rights.

In the instant case, the Court found that Way Maker was originally created by the Defendant, who had performed the song in South Africa with persons other than the Plaintiff before engaging him. The Plaintiff’s role was limited to producing the existing song as a musical work for an agreed fee, which he was paid. Accordingly, the Court held that the Plaintiff could not sustain his claim to authorship of Way Maker and described the claim as ‘gold-digging and unmeritorious.’

Issue resolved in favour of the Defendant.

Matthew Enilolobo for the Plaintiff.

Emeka Etiaba SAN with Omolola Aderolu and O. G. Ofomata for the Defendant.

This summary is fully reported at (2026) 9 CLRN in association with ALP NG and Co.

Climate change and environmental degradation are deepening the risks of displacement and insecurity across West Africa, with lawmakers at the Economic Community of West African States (ECOWAS) Parliament urging governments to move beyond national responses and adopt stronger regional solutions.

The warning came as the ECOWAS Parliament opened its Second Parliamentary Seminar and Second Extraordinary Session for 2026 in Accra, Ghana.

George Hagan, Leader of the Ghanaian delegation to the ECOWAS Parliament, said the region was facing ‘several intricate and interconnected challenges’ requiring collective action, political dialogue and stronger regional cooperation.

Hagan, who welcomed delegates on behalf of John Mahama, Ghana’s President, Jane Naana Opoku-Agyemang Vice President, Alban Sumana Kingsford Bagbin, Speaker of Parliament and the Ghanaian Parliament, said the meeting provided an opportunity to strengthen the parliamentary dimension of regional integration.

He said the participation of parliamentarians from ECOWAS member states demonstrated their shared commitment to the ideals of regional integration and the use of parliamentary diplomacy to address challenges confronting West African citizens.

According to him, the ECOWAS Parliament has an important responsibility to ensure that the voices, aspirations and concerns of citizens are reflected in regional decision-making.

‘Parliamentarians occupy a unique position within our democratic systems. We are not only legislators, but also representatives of the people, and important actors in promoting dialogue, accountability, good governance, peaceful resolution of differences and positive socio-economic and environmental development of our respective countries and the West Africa sub-region in general,’ he said.

Hagan said the role of the regional parliament had become increasingly important because many of the challenges confronting West Africa could not be effectively addressed by individual countries acting independently.

He identified climate change, environmental degradation, population displacement and insecurity as interconnected challenges requiring coordinated responses across the region.

The Ghanaian lawmaker said the parliamentary seminar and extraordinary session would provide an avenue for lawmakers to deliberate on matters of common interest and develop approaches capable of strengthening cooperation among member states.

He urged participants to use the gathering to reinforce the principles of regional solidarity, democratic governance, peace, security and sustainable development.

The seminar comes amid growing concerns across West Africa over the impact of environmental pressures and climate-related challenges on livelihoods, migration and security.

For countries already dealing with displacement and insecurity, the interaction between environmental degradation and socio-economic vulnerabilities has increasingly become a regional concern, requiring governments and regional institutions to adopt responses that go beyond national boundaries.

Hagan said parliamentarians had a particularly important role in this process because of their responsibility to represent citizens while providing oversight and contributing to policy development.

He noted that parliamentary diplomacy could help deepen dialogue among ECOWAS member states and provide a platform for lawmakers to address shared concerns and promote peaceful solutions to regional challenges.

‘The ECOWAS Parliament therefore has an important role to play in bringing the voices, aspirations and concerns of our citizens closer to the regional decision-making process,’ he said.

He added that the responsibility was even more significant at a time when West Africa was confronted with challenges that crossed national borders.

Hagan expressed confidence that deliberations during the seminar and extraordinary session would produce meaningful outcomes capable of contributing to the collective efforts of ECOWAS countries.

He also called for stronger parliamentary cooperation in addressing environmental and security challenges, while reaffirming Ghana’s commitment to the regional integration process.

‘Let us seize this opportunity to reaffirm our shared commitment to regional solidarity, democratic governance, peace, security and sustainable development,’ he said.

The Ghanaian delegation leader also welcomed the Speaker, Deputy Speakers and members of the ECOWAS Parliament, representatives of ECOWAS institutions, members of Ghana’s Parliament, government officials, members of the diplomatic corps and other participants to Accra.

He urged delegates to take advantage of Ghana’s hospitality during the meeting and encouraged them to visit tourist attractions in and around Accra.

The gathering is expected to provide a platform for lawmakers to examine the environmental, social and security dimensions of climate-related challenges and their implications for regional stability and integration.

Hagan said Ghana was honoured to host the parliamentary gathering and expressed hope that the discussions would strengthen cooperation among lawmakers and contribute to addressing the interconnected challenges confronting the West African sub-region.